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PIAC submission to COAG consultation


On 22nd September 2016, Public Interest Advocacy Centre (PIAC) provided this 2 page submission to the COAG consultation process .  In their submission, they provide support:

“PIAC agrees that an energy storage register should be established so that relevant authorities and organisations have access to critical data to fulfill their regulatory obligations. “

and:

” We also consider that the establishment a register is time-critical if it is to be effective and avoid the complexity that would ensue from the retrospective collection of the required information in the context of a rapidly evolving market. “

In the PIAC submission, they also support the submission from Dr Penelope Crossley at University of Sydney (referenced here).

In our summary page here we list the 4 key reasons we identified (up front) as to why an Energy Storage Register could be required – to which other reasons have been added as they have come to light to us (or been pointed out to us directly).

With respect to these 4 key reasons, PIAC provides these specific comments:

Reason 1 = To assist First Responders 

In their submission, support is noted for the need of First Responders – but no specific details are provided.

Where they are provided, we link to other articles referencing assistance to first responders as a reason for the Energy Storage Register.

Reason 2 = To assist in any potential future product recalls

PIAC, in their submission, stress a particular focus for the ESR in preparation for possible future product recalls:

” In particular, from a consumer perspective, PIAC agrees with the need for a national energy storage register to support compulsory product recalls and to ensure end-user safety.

Where they are provided, we link to other articles referencing potential future product recalls as a reason for the Energy Storage Register.

Reason 3 = To assist with life-cycle management

With respect to life-cycle management, PIAC notes the value of the register for:

“recycling at end-of-life and the discouragement of the dumping of hazardous waste

Where they are provided, we link to other articles referencing life-cycle management as a reason for the Energy Storage Register.

Reason 4 = To assist with electricity system operations and planning.

Brief mention is made of the “system security” requirement of the ESR in relation to electricity systems operation and planning:

Where they are provided, we link to other articles referencing electricity system operations and planning intelligence as a reason for the Energy Storage Register.

PIAC also singles out the comments from Dr Crossley about other benefits that would accrue:

Reason 5 = To provide Market Intelligence – and so to increase competition

Particular mention is made of “improved competition” that will accrue from effective data collection and dissemination.

Where they are provided, we link to other articles referencing the benefits of Market Intelligence as a reason for the Energy Storage Register.

There is repeated reference to Dr Penelope Crossley’s submission in the PIAC submission, reflecting their keen support of the recommendations therein.